L-2015-215, Fifth Overall Integrated Plan Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard with to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049)

Fifth Overall Integrated Plan Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard with to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order EA-12-049)

ML15244B203
Person / Time
Site:	Saint Lucie
Issue date:	08/20/2015
From:	Costanzo C Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, L-2015-215
Download: ML15244B203 (49)

Text

0August illglllll..*10 U.S. Nuclear Regulatory Commission 20, 2015 L-2015-215 CFR 2.202 Attn: Document Control Desk Washington, DC 20555-0001 St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Florida Power & Light (FPL)/St. Lucie's Fifth Overall Integrated Plan Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reqiuirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events dated March 12, 2012, Accession No. ML12054A736.

2. NRC Interim Staff Guidance JLD-ISG-2012-0l, "Compliance with Order EA 12 049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012, Accession No. ML12229A174.

3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August, 2012, Accession No. ML12242A378.

4. FPL Letter L-2012-385 dated October 25, 2012, FPL's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049),

dated October 25, 2012, Accession No. ML12300A421.

5. FPL Letter L-2013-084 dated February 28, 2013, Florida Power & Light (FPL)/St. Lucie's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049) , Accession No. ML13063A020.

6. FPL Letter L-2013-192 dated June 18, 2013, Florida Power & Light (FPL)/St. Lucie's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049), Accession No. ML13179A184.

7. FPL Letter L-2013-254 dated August 28, 2013, Florida Power & Light (FPL)/St. Lucie's First Overall Integrated Plan Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049), Accession No. ML13242A274.

8. FPL Letter L-2014-063 dated February 26, 2014, Florida Power & Light (FPL)/St. Lucie's Second Overall Integrated Plan Status Report in Response to March 12,.2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), Accession No. ML14064A192.

9. FPL Letter L-2014-274 dated August 27, 2014, Florida Power & Light (FPL)/St. Lucie's Third Overall Integrated Plan Status Report in Response to March 12, 2012 Commission Order 6501 S. Ocean Drive, Jensen Beach, FL 34957 },_

L-20 15-215 Page 2 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), Accession No. ML14253A184.

10. FPL Letter L-2015-049 dated February 23, 2015, Florida Power & Light (FPL)/St. Lucie's Fourth Overall Integrated Plan Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049).

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Florida Power & Light (FPL). Reference 1 was immediately effective and directs FPL/St. Lucie to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pooi cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an Overall Integrated Plan by February 28, 2013. The NRC Interim Staff Guidance (IS G) (Reference 2) was issued August 29, 2012 which endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 3 provides direction regarding the content of this Overall Integrated Plan.

Reference 4 provided the FPL/St. Lucie initial status report regarding mitigation strategies, as required by Reference 1. Reference 5 provided the FPL/St. Lucie Overall Integrated Plan pursuant to Section IV, Condition C. 1, of Reference 1. Reference 6 informed the NRC that St. Lucie was no longer pursuing reactor coolant pump (RCP) seal package modifications as part of the FLEX strategy.

References 7, 8, 9, and 10 provided the FPL/St. Lucie first, second, third, and fourth six-month Overall Integrated Plan status report.

The purpose of this letter is to provide the fifth six-month Overall Integrated Plan status report. The information in the enclosure is based on conceptual design information that is current as of this letter.

As design details and associated procedural guidance are finalized, additional information, as well as revisions to the information contained in the enclosure to this letter, will be communicated to the NRC in the 6-month Integrated Plan updates as required by Reference 1.

This letter contains no new regulatory commitments.

L-2015-215 Page 3 If there are any questions regarding this submittal, please contact Eric Katzman, St. Lucie Licensing Manager, at (772) 467-7748.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on . ,3 t 2-3_, 2015.

Respectfully submitted, Christopher R Costanzo Site Vice President St. Lucie Plant CRC/KWF cc: USNRC Regional Administrator, Region II USNRC Senior Resident Inspector, St. Lucie Units 1 and 2

Enclosure:

Fifth Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

L-2015-215, Enclosure Fifth Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Florida Power and Light (FPL) developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Reference 3 for the St. Lucie plant. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

To simplify review of impacts the six-month updates have on the original Overall Integrated Plan (Reference 1),

this fifth six-month update has been formatted as a revision to the fourth six-month update (Reference 19), thus keeping all updates in one document; changes since the fourth six-month update are reflected via revision bars in the right-hand margin. National SAFER Response Center (NSRC) has replaced Regional Response Center (RRC) in the document except for NRC review items in Section 6.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 1). Milestone accomplishments are current as of July 21, 2015.

• Submittal of First 6-Month Status Report, August 2013 (Reference 6)

• FLEX Strategy (Preliminary) Walkthrough Demonstration

• Submittal of Second 6-Month Status Report, February 2014 (Reference 14)

• Submittal of Third 6-Month Status Report, August 2014 (Reference 17)

• Submittal of Fourth 6-Month Status Report, February 2015 (Reference 19)

• Submittal of Fifth 6-Month Status Report (This Document) 3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed. An additional milestone for FLEX Strategy Walkthrough Demonstration has been added per NEI template revision. The revised milestone target completion dates do not impact the order implementation date.

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L-2015-215, Enclosure Revised Target Target Milestone Completion Date Activity Status Completion Date Submit Overall Integrated Plan Feb 2013 Complete Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Complete Update 4 Feb 2015 Complete Update 5 Aug 2015 Complete FLEX Strategy Evaluation - Final Fb21 tre eebr21 Implementation Plan (FlIP)

FLEX Strategy Walkthrough Demonstration Feb 2014 Complete Perform Staffing Analysis Oct 2014 Complete Modifications:

Unit 1 Implementation Outage Mar 2015 Complete Unit 2 Implementation Outage Nov 2015 Started Storage:

Storage Implementation Mar 2015 Complete FLEX Equipment:

Procure On-Site Equipment Oct 2014 Complete Procedures:

Create Site-Specific FSGs Mar 2014 Unit 1 Complte, August 2015 Unit 2 Starlted Create New/Revisions to OPS Procedures Mar 2014 Unit 1 Complted uut21 Create Maintenance Procedures Mar 2014 Complete Training:________

Develop Training Plan June 2014 Complete TrainingCompleteMar 2015Unit 1 CompleteAust21 TrainingCompleteMar 2015Unit 2 Started Agst25 Unit 1 FLEX Implementation Mar 2015 Complete Unit 2 FLEX Implementation Nov 2015 Started Full Site FLEX Implementation Nov 2015 Started 4 Changes to Compliance Method 4.1 RCP Seal Modification The Reference 1 (page 35 of 102) FLEX response indicated St. Lucie would modify' the seals for the reactor coolant pumps of both units to include Flowserve Abeyance seal stages. Reference 2 revised the St. Lucie FLEX strategy to maintain the current Flowserve N-9000 RCP seal configuration without making a Page 2 of 46

L-2015-215, Enclosure Flowserve Abeyance seal modification. The existing St. Lucie seal configuration is consistent with the N-9000 RCP seal configuration evaluated in WCAP-17601-P, "Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs" (Reference 5) and with the approaches adopted by other Combustion Engineering NSSS plants that currently utilize the Flowserve N-9000 seal. Note that both St. Lucie units have excess flow check valves in the RCP controlled bleed off (CBO) lines and, additionally, have fail closed isolation valves to isolate the CBO leakage pathway. Station Blackout Emergency Operating Procedures, have an early positive step to isolate the CBO leak path on loss of seal cooling; these procedures will be revised to require that isolation within 10 minutes post event - see Pending Action 73A.

As part of the revised RCP seal approach, St. Lucie will initiate the reactor coolant system cooldown to a steam generator pressure of 120 psia in a 2-6 hour timeframe as opposed to the 10-14 hour timeframe originally indicated in Reference 1. This action is compliant with WCAP- 17601-P and eliminates the deviation previously indicated within Reference 1 Attachment lB, NSSS Significant Reference Analysis Deviation Table.

4.2 Condenser Makeup Lines The Reference 1 FLEX response (page 22 of 102) stated that non-seismic condenser makeup lines from the CST would be seismically qualified to provide an additional qualified water inventory for hot standby and cooldown. In a seismic scenario, the qualified contents of the two CSTs and two RWTs will be available to provide approximately 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> of Phase 2 coping time. There is reasonable assurance that volumes of one or more non-qualified tanks may also be available. Entry into Phase 3 shutdown cooling (SDC) is expected well before use of makeup of seawater from the Ultimate Heat Sink would be anticipated. Accordingly, the current FLEX strategy does not include a modification to seismically qualify the condenser makeup lines.

4.3 Mechanical Connections The St. Lucie FLEX strategy for making mechanical system connections has evolved from that indicated in Reference 1 response figures to be consistent with NEI 12-06 guidance (Reference 4). Secondary connections may require reconfiguration (e.g., removal of valve bonnet or disassembly of a flanged pipe joint) if validated that time and resources are reasonably available to support the reconfiguration. Locations of the connection points provide reasonable assurance that at least one connection will be available for all applicable hazards. Refer to attached revised mechanical connection Figures 11, 12 and 14 for the latest changes.

4.4 Electrical Connections The St. Lucie FLEX strategy for making electrical system connections has evolved from that indicated in the Reference 1 response figures to be consistent with NEI 12-06 guidance (Reference 4). Refer to attached final revised electrical connection figures. Note the 480 volt connections will now be made using procedurally controlled breakers rather than using transfer switches.

Question 25 of audit document Order EA- 12-049 Mitigation Strategies, Overall Integrated Plan Regulatory Audit Questions, St. Lucie 1 & 2, Rev. 1, Dated October 30, 2013, questioned the St. Lucie FLEX strategy for isolation of Class lE Electrical equipment from portable/FLEX equipment. The FPL response was to provide a double isolation scheme with appropriate coordinated current interrupting devices. In lieu of the double isolation concept, FPL has decided that during normal operation, these new breakers will be racked Page 3 of 46

L-2015-215, Enclosure out and locked open with springs discharged. Under this arrangement, isolation between the Class 1E Electrical equipment and portable/FLEX equipment is maintained.

In the same question regarding prevention of multiple sources powering the electrical buses, the strategy provided was that for Phase 3, the scheme would rely on electrically interlocked breakers of the incoming feeder breakers with the FLEX circuit breaker such that both breakers must be OPENED before the FLEX circuit breaker can be closed. The present strategy has evolved to having all the connections for FLEX power connection and breaker positioning be procedurally controlled. This strategy has evolved due to the less restricting time frame for Phase 3 coping.

4.5 Boration Requirements for Shutdown Margin The Reference 1 FLEX response (page 37 of 102) discussed boration requirements for shutdown margin.

FPL has adopted the position expressed by the NRC staff regarding the boron mixing issue for PWRs (Reference 7) - see Pending Action 17 and Open Item 3.2.l.8.A in Section 6. The NRC letter states that the NRC staff has reviewed the information submitted to date and concluded that use of the industry approach documented in Reference 8 is acceptable with clarifications listed in the letter. FLEX guidelines have been developed that address sub-criticality for Phase 1/2 (300°F) and Phase 3 (50°F) including sources and timing for adding borated water. Guidelines include monitoring of Thot and Teold to ensure single phase Natural Circ. AT conditions exist prior to adding boron and the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> mixing delay is included prior to entering conditions requiring additional boration 4.6 NSRC LIUHS Pump The Reference 1 FLEX response (page 68 of 102) indicated a pump would be provided from the National Safer Response Center (NSRC) to replace the function of the Intake Cooling Water Pumps due to the Loss of Ultimate Heat Sink (LUHlS) event. The design point of the SAFER NSRC pump is 5000 gpm at 150 psi. The LUHlS Pump criteria mentioned in Reference 1 (page 72 of 102; 7162 gpm, 90 psi) is altered to align with SAFER provided equipment. The nominal flow rate of 5000 gpm is adequate for Shutdown Cooling in the timeframe for entry some 72-120 hours after shutdown while maintaining the Intake Cooling Water systems within their design temperature limits. The NSRC generic pump has inadequate suction lift for the intended deployment of the NSRC pump on the intake structure deck. A pair of NSRC supplied diesel/hydraulic driven suction booster pumps will be used to provide the required lift capability for each SAFER NSRC pump. This pump combination will allow water to be drawn from the intake structure downstream of the traveling water screens (non-seismic) to address debris concerns in a hurricane scenario. A backup plan will locate the floating booster pumps within the intake canal.

4.7 Makeup Water Sources The St. Lucie FLEX makeup water strategy has evolved from that indicated in the Reference 1 response crediting two Condensate Storage Tanks (CSTs) and one Refueling Water Tank (RWT - borated water source). The current strategy is consistent with NEI 12-06 guidance (Reference 4), including their response to FLEX Guidance Inquiry 2013-11, "Use of Raw or Untreated Water".

For a seismic based event, the current FLEX strategy credits water volumes within the CSTs and RWTs of both units. All four tanks are seismically qualified, as is the cross-connect line between the CSTs. Tank inventories above the lowest non-seismic line are not credited.

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L-2015-215, Enclosure For a high wind-hurricane based event, sufficient warning time will be available to ensure site tanks, e.g.,

CSTs, RWTs, City Water Storage Tanks (CWSTs), Treated Water Storage Tank (TWST) and Primary Water Storage Tanks (PWSTs), are filled with water. Analysis using current licensing basis criteria indicates that water-filled tanks are qualified for a hurricane wind event. Current plant severe weather preparations procedures require all water tanks to be filled when a hurricane watch or warning has been declared. The current FLEX strategy credits the water volumes within the subject tanks for a hurricane event.

For a high wind-tornado based event, site tanks will be pre-filled, as required by administrative procedures.

With respect to tornado winds and missiles, the Unit 2 CST volume is fully qualified and reference 18 provides reasonable assurance that the Unit 1 CST is tornado missile protected. Reference 18 also provides reasonable assurance that other major tanks (RWTs, CWSTs, TWST and PWSTs) are tornado missiles protected based on their design, separation and intervening structures; the CWSTs, TWST and/or PWSTs should be available as secondary sources of water to provide makeup to the CSTs/RWTs during Phase 2 following a high wind missile event. An alternate makeup water strategy credits the underground water Supply line from Fort Pierce Utilities (FPU), the local potable water supplier. Rather than missile protecting the single existing source from tornado, a second source will be installed and separated by greater than diameter of typical tornado path (1200 ft) with that path oriented from the west to southwest. See new Figure 23.

4.8 RWT Cross-Connect As stated in the Reference 1 FLEX response (page 18 of 102), the Unit 1 & 2 RWTs are not currently cross-connected. The FLEX response indicated that, as required by the tank evaluations, the RWTs would be cross-connected with a seismically qualified, missile protected line to allow either RWT to be aligned for gravity flow to the SDC piping of either unit. Based on the numerous potential makeup water sources discussed above, as well as guidance provided in the NEI response to FLEX Guidance Inquiry 2013-10, "Shutdown Mode Capability Requirements for PWRs", the current FLEX strategy does not include a modification to install an RWT cross-connect line.

4.9 DC and Extended DC Load Shedding The St. Lucie DC coping strategy has evolved from that indicated in the Reference 1 response which was to perform load shedding on both safety related batteries. The revised strategy will be to initially secure one battery, load shed/operate on the other battery and return the secured battery to service before the first battery is depleted (and then secure the first battery). This approach will improve battery margin by using the two batteries in a series operating mode. Analysis indicates this shedding is capable of increasing the duration of the battery powered instrumentation monitoring function on Unit 1 to approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for each 1A and lB station batteries (21.5 hrs. total) and on Unit 2, 9.6 and 7.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for 2A and 2B station batteries, respectively (14.98 hrs. total). - see Pending Action 26A and Confirmatory Item 3.2.4.10.A in Sections 6 and 6A, respectively.

4.10 Steam Generator Makeup - Mode 1-4 The Reference 1 FLEX response indicated a portable pump (FLEX SG Pump) would be used to provide makeup to the steam generators as a backup source should the existing turbine driven Auxiliary Feedwater Pump fail. The pump will be sized to provide 300 gpmn at 300 psi discharge (steam generator ring pressure) while drawing from the Condensate Storage Tank. Actual makeup requirements (nominally 130 gpmn Page 5 of 46

L-2015-2 15, Enclosure following cooldown) are considerably less than the 300 gpm design point. The FLEX CST Pump will be used to replenish the Condensate Storage Tank from available site water sources with ultimate backup from the intake (seawater). The FLEX CST Pump will replenish the Unit 2 CST in the cases of Unit 2 or dual Unit coping following a Beyond Design Basis External Event (BDBEE). Unit 1 CST makeup will be via the CST cross connect line in the dual Unit coping case. The FLEX CST Pump will replenish the Unit 1 CST in the case of a Unit 1 only coping following a Beyond Design Basis External Event (BDBEE). The dual Unit CST makeup requirement for TDAFW Pump or FLEX SG Pump is nominally 130 gpm per Unit as stated above and, thus, the flow requirement for the FLEX CST Pump is reduced from the 300 gpm per Unit to 250 per Unit as tabulated on Page 70 of 102 in Reference 1. The resultant oversupply provides adequate capability to raise CST levels once makeup is implemented. The FLEX SG Pump will also be capable of drafting from the intake canal at a flowrate near to, but somewhat below, the 300 gpm/300 psi design point.

4.11 Mode 5 & 6 Strategies NEI 12-06 (Reference 4) states that the FLEX strategies are not explicitly designed for outage conditions.

FPL will incorporate the supplemental guidance provided in the NEI position paper entitled "Shutdown /

Refueling Modes" to enhance the shutdown risk process and procedures (see Reference 9 and 10), as well as that provided in the NEI response to FLEX Guidance Inquiry 2013-10, "Shutdown Mode Capability Requirements for PWRs". As such, pending actions associated with these modes have been closed, including those associated with boron batching alternatives since they are no longer required - both the Unit 1 and Unit 2 RWTs are now considered available to cope with an event during Mode 5 & 6.

4.12 FLEX Equipment Storage The Reference 1 FLEX response indicated the FLEX Equipment Storage Building (FESB) will be 170' x 70' and will be capable of housing all required FLEX equipment, including required spares ("+ 1" equipment).

The FLEX strategy has evolved to incorporate NEJ 12-06 guidance (Reference 4), including their response to FLEX Guidance Inquiry 2013-07, Reasonable Protection", that spare equipment need not be stored in the FESB. The spare equipment will now be stored elsewhere on site, resulting in a smaller FESB footprint (150' x 60'). The Reference 1 FLEX response also stated the FESB will include natural ventilation to maintain temperatures within the manufacturer's recommendations; in lieu of natural ventilation, air-conditioning is now being provided, which will also limit humidity extremes inside the FESB.

Note that the Reference 1 FLEX response stated the refueling of diesel fuel oil driven equipment will be accomplished via a trailer stored in the FESB, on which will be mounted a 500-gallon tank. The tank size has been evaluated and a 1000 gallon trailer mounted tank is being procured. Gravity fill of this tank has been revised to use V 17202 or one of two new redundant valves that have been installed on the fill line. See new Figure 24.

4.13 Maintenance and Testing of FLEX Equipment FPL will comply with the EPRI generic industry program for maintenance and testing of FLEX equipment as delineated in References 11 and 12.

4.14 Sequence of Events Timeline The Reference 1 FLEX response included Sequence of Events Timelines. A new action in the Modes 1-5, SGs Available timeline for RCP Control Bleed Off isolation is added at 10 minutes to limit RCP leakage.

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L-2015-21 5, Enclosure This addresses Confirmatory Item 3.2.1.1 .A. Note that these timelines are under review and may be adjusted via a future six-month update based on ongoing evaluations and development of FLEX strategies. Review is complete on several of these timelines and resulting further changes are:

1. DC and Extended DC Load Shedding are to be performed at 1.0 - 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> or within 90 minutes of the Station Blackout. Analysis indicates this shedding is capable of increasing the duration of the battery powered instrumentation monitoring function on Unit 1 to approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for each 1A and lB station batteries (21.5 hrs. total) and on Unit 2, 9.6 and 7.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for 2A and 2B station batteries, respectively (14.98 hrs. total).

2. Deployment of the FLEX SG Pump is to be performed at 2- 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to be connected for TDAFW Pump backup. This will support the early RCS cooldown strategies that have SG secondary depressurized to a level that the FLEX SG Pump is able to provide required flow at between 4 and 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

3. Restoration of power to the SIT outlet MOV's will be performed at 8-11 hours. This will allow any necessary SIT isolation to be performed to prevent nitrogen injection that may occur due to RCS shrinkage and leakage.

4.15. Instrumentation Credited for Coping Evaluations The Reference 1 FLEX response included lists of instrumentation credited for coping evaluations supporting FLEX Strategies that Maintain Core Cooling & Heat Removal, Maintain RCS Inventory Control and Maintain Containment. Several of the instrument tags listed have been revised to provide improved sensing range and to be aligned with the power supplies that will be available under the DC Loading Shedding strategy (described in 4.9 of this attachment). Note that the parameters listed under these FLEX Strategies in the Reference 1 FLEX response are not revised.

4.16 FLEX SFP? Pump Discharge The Reference 1 FLEX response described the hardened makeup flowpath to Maintain Spent Fuel Pool Cooling as via the 21/2/" ICW lines on the exterior east wall of each Fuel Handling Building (FHB). In lieu of providing missile protection for these lines, an alternate missile protected flow path will be provided. The alternate path is via a new FLEX connection on the suction of one of Spent Fuel Pool Pumps on each unit.

These lines and their flow paths to the Spent Fuel Pools are within the missile protected interior of the FHB's. The 21/2"ICW lines remain the preferred hardpipe flowpath should they remain intact following the BDBEE. See new Figure 22.

4.17 FLEX Strategy Internal Flooding Question 2 of audit document Order EA- 12-049 Mitigation Strategies, Overall Integrated Plan Regulatory Audit Questions, St. Lucie 1 & 2, Rev. 1, Dated October 30, 2013, questioned the St. Lucie FLEX strategies address considerations for seismic hazards associated with large internal flooding sources that are not seismically robust. The FPL response was that internal flooding was a concern for access to the ECCS Pump rooms and that no AC power was required to access those rooms. In addition, internal flooding has been considered for FLEX Equipment deployment. The FLEX Strategy for RCS Makeup requires hose deployment to connections on the LPSI pump piping that is located behind the watertight doors to the ECCS Pump rooms. Access into the watertight doors is via the -0.5 ft hallways whose design bases internal flood level (from non-seismic Unit 2 Holdup Tank ruptures) is above the watertight door thresholds. To facilitate hose deployment, a modification to the watertight doorways has been implemented to allow insertion of a flood barrier. This limits the volume of water entering the LPSI pump rooms to that between the barriers and the doors.

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L-2015-215, Enclosure 4.18 FLEX Equipment +1 Spares PSL does not intent to have a complete set of spare hoses and cables but will accomplish +1 by having the greater of (1) 10% of the "N1" required spares or (2) those sections of hose and cables required to replace the longest run of each hose or cable type and size needed for FLEX Strategies.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FPL expects to comply with the order implementation date. No relief/relaxation is required at this time.

6 Pending Actions from Overall Integrated Plan and Draft Safety Evaluation Overall Integrated Plan Pending Actions Status 1 Seismic re-evaluation of site and submit to NRC. Include Complete. PSL has screened out. FPL insights in development of the FLEX integrated plan Letter L-2014-215 (Ref. 15) 2 Flooding re-evaluation of site and submit to NRC. Include Complete, Flooding re-evaluation was insights in development of the FLEX integrated plan submitted to the 10, 048 sent March NRC via FPL Letter L-20 15-2015 3 Establish location of NSRC Staging Area (outside of 25 mile Complete. Staging areas have been radius) established with SAFER review.

Complete, BC 282155, Attachment - "WP-Soil 4 Review FESB deployment routes for liquefaction Liquefaction White Paper" was issued to address FLEX route liquefaction 5 Determine NSRC staging area location and develop Complete. Staging areas have been deployment routes to site established with SAFER review.

6 Review Communications adequacy during Phase 2 staffing Complete study 7 Review Extend DC Shedding Approach regarding potential Complete, Failure Analysis of active spurious actions components performed.

8 Determine alternate plant locations for obtaining critical Complete, included in FSG' s parameters remotely 9 Review 480 VAC Diesel Generator FLEX Sizing Complete. 350 kW DG/unit is required 10 Review 4.16 KVAC Diesel Generator NSRC FLEX Sizing Complete. NSRC 2MW unit is acceptable 11 Analysis to maintain acceptable CR temperatures during Complete, CR Calc FPL-064-CALC-008 ELAP, identify additional required strategies!/modifications revised to show maximum temp of 11 00 F 12 Review EER operation up to 129°F for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or provide Complete, EER Calc FPL-064-CALC-007 portable fans, initiate FSG/Time Validation as required revised to show acceptability of 129°F 13 Qualify Ul CST regarding tornado wind hazards, identify Complete, Ref. 18 provides reasonable any equred odiicatonsassurance that the CST is tornado missile any equred odiicatonsprotected 14 Qualify RWT(s) regarding tornado wind hazards, identify Complete. No modifications required. See any required modifications Section 4.7 and 4.8 Page 8 of 46

L-2015-215, Enclosure Overall Integrated Plan Pending Actions Status 15 Review boron batching alternatives, determine approach, Complete. Not Required. See Section 4.7 identify required modifications and 4.11 16 Perform analysis supporting survivability of one or more Complete, Ref. 18 provides reasonable non-qualified water tanks assurance that one or more non-qualified tanks is tornado missile protected 17 Finalize boration requirements for Cold Shutdown Margin and timing of injection with electrical power availability. Complete. Letdown modification is not Ensure letdown flow is not required or provide modification required. See Section 4.5 to provide letdown. Update milestone as necessary.

18 Review boron precipitation during Phase 1&2 (pool boiling) Closed - Not Required. See Section 4.11 and Phase 3 (final cooldown) for Mode 6&5 w/o SGs 19 Evaluate establishment of contract or letter of agreement for Complete water supply by tanker trucks 20 Review MS containment vent path (RWT gravityClsd-NtRqie.Seecon41 feed/Containment overpressure) Consider LCO 3.9.4,Clsd-NtRqie.Seecon41 RAB/CR ventilation. Confirm adequacy of Unit 2 8" (Ntch)veed Hai- ilno s 0"E p purge line size. Hth 21 Review potential modification for an 8" relief path to Closed - Not Required. See Section 4.11 prevent U1 containment overpressure in MS (and note above) 22 Review safeguard equipment initiation with respect to MS Complete. Not Required. See Section 4.11 containment vacuum analysis (Note: Reviewed; will lockout equipment) 23 Review LUHS Pumping System NSRC FLEX Sizing Complete - NSRC LUHS Pumping System adequate - See Section 4.6 24 Ensure FHAB L-shaped door can be opened in the required Complete, alternate venting using time frame or identify alternate venting approach personnel & new fuel entrance doors adopted. See Section 6B, Item AQ 14.

25 Provide Technical Basis for WCAP-1760 1-P deviations to Onog.NdeitnsSeScin41 NRC during six month updatesOnon.NdeitnsSeScin41 25A Time validation study for isolation of controlled bleed off Complete and acceptable; CBO lines can (CBO) lines within 10 minutes be isolated within 10 minutes post event Complete and acceptable for current 26 Tme stdyalidtio fr cmpleingDC oad heding strategy - Unit 1: ~-30 minutes; Unit 2:

26 Tme stdyalidtio fr cmpleingDC oad heding30 minutes (inverters)/one hour within specified time period (balance); to be re-evaluated (see Action 26A below) 26A Time validation study for completing revised DC load Complete - Unit 1 and Unit 2 load shed shedding discussed in Section 4.9 within specified time validated at -30 minutes. Control Room period, to include any impact to required instrumentation impact determination complete with and Control Room heat up acceptable temperature maintained.

27 Time validation study for Control Room ventilation Complete Page 9 of 46

L-2015-215, Enclosure Overall Integrated Plan Pending Actions Status Closed - Not Required. On Unit 1, Battery Room roof exhausters will be powered when the battery room chargers are placed in operation; both will be powered by same FLEX 480V portable diesel-generator. On 28 Time validation study for Battery Room ventilation Unit 2, Battery Room doors will be open and rooms ventilated via FLEX 480V FLEX DG repowered Electrical Equipment Room ventilation when the battery room chargers are placed in operation.

29 Time validation study for Electrical Equipment Room Cmlt ventilation Cmlt 30 Time validation study for FFHB ventilation and the deployment and staging of SFP makeup/spray capability Complete 31 Time validation study for 480 VAC diesel generator to the Cmlt station 480 VAC bus Cmlt 32 Time validation study for CST non-seismic lines isolation, Coe o plcbe e eto .

as required by design Coe o plcbe e eto .

33 Time validation study for CST cross-connect Complete 34 Time validation study for FLEX CST pump deployment Complete 35 stdy or LEXSG pmpsforCSTAFW Tme aliatin Complete and acceptable; pumps can be 35 Tme stdyaliatin or LEXSG pmpsforCSTAFW deployed five hours post event) 36 Time validation study for boration to establish Cold Cmlt Shutdown Margin (M1-4 w/SGs) Cmlt 37 Time validation study for establishing power to SIT MOVs Complete to isolate 38 Time validation study for establishing RWT gravity flow Clsd-NtApiae.Seecon41 path to RCS (include mid-loop conditions) 39 Time validation study for FLEX SG pump for RWT/RCS Closed - Not Applicable. See Section 4.11 40 Time validation study for batch boration to maintain borated Closed - Not Applicable. RWT available water supply (M6 & 5 w/o SGs) for makeup use. See Section 4.7 and 4.11 41 Time validation study for venting containment in mid-loop Clsd-NtApiae.Seecon41 conditionsClsd-NtApial.SeSton41 42 Time validation study for isolating Fuel Transfer Tube path. Closed - Not Applicable. See Section 4.11 43 Time validation study for establishing containment vent Clsd-NtApiae.Seecon41 44 Time validation study for isolating CCW Flow toClsd-NtApiae.Seecon41 45 Time validation study for hoses for SFP makeup/spray in Complete Phase 1 46 Time validation study for FLEX SFP pump Complete Page 10 of 46

L-2015-215, Enclosure Overall Integrated Plan Pending Actions Status 47 Time validation study for refueling FLEX equipment Started 48 U1 & U2 Construct FLEX Equipment Storage Building Construction Completed Storage Building 49 Ul & U2 Install external satellite phone antenna and Complete - Antennas and stations installed docking stations for TSC & EOF 50 U 1 & U2 Install new cabling with disconnects for MCC supplying battery chargers. Alternate connections line side Coe o plcbe e eto .

51 Ul & UJ2 Change essential instrumentation source to vital Unit 1 Complete, Unit 2 Started (Design 120 VAC power panel Issued: EC 280773 Unit 2) 52 U1 & U2 Install cabling to Class lE 480 VAC Switchgear Unit 1 Complete, Unit 2 Started (Design A&B for primary and alternate connection of 480 VAC Issued: EC 280771 Unit 2)

FLEX DG 53 Ul & U2 Install transfer switches on load side charging* Closed - Not Applicable. See Section 4.4 pumps and Class 1E battery chargers. Alternate connection.

54 Ul & U2 Design cabling/disconnects for Class lE 4.16 Closed -Not Applicable as cables will be KVAC busses A&B connected via procedure. See Section 4.4 55 Ul & U2 Install RCP low leakage seals Closed - Not Applicable. See Section 4.1 56 Ul Install ADV seismic pneumatic backup and air pressure Complete regulator, provide quick connects Complete and acceptable; Operator actions 56A Ul Time validation study for ADV Operator actions can be completed within 90 minutes post event 57 Ul Install modifications for CST as required by tornado Complete, Ref. 18 provides reasonable wind anaysisassurance that the CST is tornado missile wind azar azar anaysisprotected 58 Ul & U2 Qualify non-seismic lines penetrating CSTs or use Coe o plcbe e eto .

another approach to qualify additional CST inventory 59 U1 & U2 Qualify non-seismic CST cross-connect Complete 60 Ul & U2 Install 2 connections per CST for refilling the Unit 1 Complete, Unit 2 Started (Design CSTs via FLEX CST pump Issued: EC 279191 Unit 2) 61 Ul & U2 Install 2 connections per CST for suction point for Unit 1 Complete, Unit 2 Started (Design FLEX SG pump Issued: EC 279191 Unit 2) 62 U 1 & U2 Install 2 connections on AFW lines upstream of Unt1Cmleni2Sard(Dsg MVs for FLEX SG pump to symmetrically feed both steam IsudEC291Unt) generators 63 Ul & U2 Install single connections for taking suction on Unit 1 Complete, Unit 2 Started (Design non-qualified tanks Issued; EC 278639) 64 U1 & U2 Install modifications for RWT as required by Closed - Not Required. See Section 4.7 tornado wind hazard analyses and 4.11 65 U1 & U2 Install RWT cross-connect sized for gravity fill as Coe o plcbe e eto .

required by tornado wind hazard analyses Page 11 of 46

L-2015-215, Enclosure Overall Integrated Plan Pending Actions Status 66 U 2 cnnetios

& 2 Intal pe RW forsucionUnit 1 Complete, Unit 2 Started (Design 66nstll2 1 &U2cnnetios pr WT or uctonpoint issued and fabrication of connection piping for FLEX SG pump/FLEX CST Pump initiated: BC 279191 Unit 2) 67 U1 & U2 Install 2 connections per RWT for CST FLEX Unt1Cmleni2Sard(Dsg issued and fabrication of connection piping pump discharge initiated: BC 279191 Unit 2) 68 U1 & U2 Install 2 connections on LPSI pump discharge Unit 1 Complete, Unit 2 Started (Design issued and fabrication of connection piping piping for RCS cold leg inj ection via FLEX pump initiated: BC 279191 Unit 2) 69 U2 & 2 Istal o LPI pup sctin onnctios . Unit 1 Complete, Unit 2 Started (Design 69 IstalU 2conectins

& 2 n LSI umpsucionpiping issued and fabrication of connection piping (Mode 6 with Rx head off/SG primary manways off) initiated: EC 279191 Unit 2) 70 U1 Provide containment vent path to ensure sufficient RWT Clsd-NtRqie.Seecon41 gravty RS maeup(Note:

fow or Reviewed; will now use 30" Escape gravty RS maeupHatch) fow or 71 Ul & U2 Missile protect ICW line I-2 1/2/-CW-178 located Clsd-NtRqie.Seecon41 on the exterior of U1 & U2 FI-TJs 72 U1 & U2 Install ICW manifolds with hose connections and Ui n nt2Cmlt isolation valves for LUHlS 73 Create new site procedures, including one(s) for use of Complete - Hard Cards attached to phones Satellite communications 73A Revise existing site procedures, including EOPs to reflect Complete - 1/2-EOP-10 revised isolation of CBO lines within 10 minutes post event Started - 1-FSG-99 issued, 2-FSG-99 74 FSG: Establishing FLEX Control Room Ventilationstre Started EOP-l10 revised, 2-EOP-l10 75 FSG: Extended DC bus load shedding revision started, 1-FSG-04 issued, 2-FSG-04 started Started - 1-FSG-05 issued, 2-FSG-05 76 FSG: Damage assessment following event started 77 FSG: Accessibility considerations for personnel to enter Started - 1-FSG-05 issued, 2-FSG-05 areas to perform local manual actions started 78 FSG: Deployment and staging of portable equipment (Onsite Started - l-FSG-99 issued, 2-FSG-99 and Offsite) started 79 FSG: Operation of the FLEX equipment (startup, shutdown, Started FSG-99 issued, 2-FSG-99 operational monitoring, minor troubleshooting started 80 FSG: Operation of DFO transfueler, filling from U2 DFO Started FSG-99 issued, 2-FSG-99 tanks, filling FLEX portable equipment, etc. started 81 FSG: Restore AC power or alternate power sources for Started FSG-99 issued, 2-FSG-99 specific plant equipment started 82 FSG: Lighting and communications necessaiy for ingress Started FSG-99 issued, 2-FSG-99 and egress to plant areas for deployment of FLEX strategies started Page 12 of 46

L-2015-215, Enclosure Overall Integrated Plan Pending Actions Status 83 FSG: Deployment and operation of 480 VAC diesel Started FSG-99 issued, 2-FSG-99 generator started 84 FSG: Power restoration with ESF signals present due to de- Started FSG-07 issued, 2-FSG-07 energized instrument inverters started 85 FSG: Repowering selected station loads to support long term Started FSG-13 issued, 2-FSG-13 safety functions (load management) started 86 FSG: Operation of AD Vs with backup compressed gas Complete EOP-99 issued Started FSG-06 issued, 2-FSG-06 87 FSG: Deployment and operation of FLEX CST pump started 88 FSG: Maintaining flow to SGs, with identified backup Started - l-FSG-03 issued, 2-FSG-03 sources and criteria for transferring between sources started Started - l-FSG-03 issued, 2-FSG-03 89 FSG: Deployment and operation of FLEX SG pump started Started EOP-l10 revised, 2-EOP-l10 90 FSG/EOP-10 to address for FLEX RCS cooldownreionsatdlFG-8ndlSGl (cooldown, solid plant conditions, SIT isolation, Attach 1B) reissued stred2-FSG-08 2FG1-FStarte and Started - l-FSG-l0 issued, 2-FSG-10 91 FSG: Guidance for SIT injection and isolationstre 92 FSG: Establish RWT gravity flow to RCS and criteria for Started AOP-99.02 issued, 2-AOP-transfer to FLEX SG pump 99.02 started Closed - Not Applicable. RWT available 93 FSG: Guidance for boron mixing for makeup use. See Section 4.7 and 4.11 Started FSG-1 1 issued, O-FSG-1 1 94 FSG: Deployment and operation of FLEX SEP pump started 95 FSG: Guidance for isolation of CCW penetrations for CFC Clsd-NtApiae.Seecon41 Coolers 96 FSG: Guidance for venting containment in M5/6 Once- Clsd-NtApiae.Seecon41 Through-Cooling with LUHlS (include CS Lockout) 97 FSG: Deployment and operation of NSRC 4.16 KVAC Complete EOP-99 issued generator 98 FSG: Deployment and operation of NSRC pumping system Complete EOP-99 issued for ICW 99 FSG: Deployment and operation of FLEX SG pump: Closed - Not Applicable. See Section 4.11 injection for vapor bound LPSI pump 99A FSG: Transition from FLEX Equipment to Plant Equipment Started FSG-13 issued, 2-FSG-13 started 100 Implement FLEX program stipulating the requiredCopee-AM134isd administrative controls to be implementedCopee-AM1.4isd 101 Confirm adequacy of access provisions for locked areas Stre-lFG05isd,2S-5 affected by loss of ac power and address any additional stre guidance or procedure upgrades required Page 13 of 46

L-2015-215, Enclosure Overall Integrated Plan Pending Actions Status 102 Provide final versions of electrical one-line diagrams in a Cmlt future six-month update. Cmlt 103 Provide update of any changes to dc coping strategy Complete. See Section 4.9 104 Ul & U2 Install 1 connection on one SFP Pump suction line Complete. See Section 4.16 for SFP FLEX pump discharge 105 Install two sets of secondary water supply connections from Copee-Nwudrondmis underground water main (Ft. Pierce Utilities) at north and sttonseta cn end etiouns minstale new south metering stations sain n oncin ntle 106 Install removable flood barriers at watertight doors to ECCS Complete. See Section 4.17 Pump Rooms.

Alpha suffixes and numbers above 100 indicate additional items beyond those identified in Reference 1 Draft Safety Evaluation Pending Items Status Draft NRC Safety Evaluation has not been received. Draft FIP N/A submitted to NRC during November, 2014 Audit Visit 6A Open and Confirmatory Items from Interim Staff Evaluation The NRC Interim Staff Evaluation and Audit Report on the St. Lucie Overall Integrated Plan have been received via Reference 13. Responses to the following two Open Items and 15 Confirmatory Items have been developed.

Where responses have been developed though not completed or reviewed by the NRC, brief summary remarks are added to the Notes section with St. Lucie response white paper tracking number:

Open Items Item Number Description Notes 3.2.1.8 .A Core Sub-Criticality - Confirm that St. Lucie will apply St. Lucie will apply the generic the generic resolution for boron mixing under natural requirement per Reference 16 circulation conditions potentially involving two-phase regarding conditions and timing flow, in accordance with the conditions provided in the for boron mixing. Response to be NRC's endorsement letter dated January 8, 2014, or included with Program alternately, justify the boric acid mixing assumptions that Document.

will ensure adequate shutdown margin exists through all three phases of an ELAP event.

Page 14 of 46

L-2015-215, Enclosure Item Number Description Notes 3.2.1.8.B The St. Lucie RCS Inventory coping strategy involves an St. Lucie repowering and use of alternate approach relying on repowering one of three an installed charging pump as an installed charging pumps in each unit using a portable alternate coping strategy is 480 VAC FLEX generator. Justify how these installed currently being evaluated.

pumps will be capable of performing their mitigating Response to be included with strategies function following an undefined ELAP event, Program Document.

in contrast with using a portable FLEX pump.

Confirmatory Items Item Number Description Notes 3.1.1 .2.A Confirm that the routes for deployment of FLEX St. Lucie has ensured that the equipment provide for at least one connection point for FLEX equipment staged locations the FLEX equipment that will only require access and cable/hose routes are through seismically robust structures, consistent with protected from seismic events or consideration 2 of NEI 12-06, Section 5.3.2. allow for multiple placement locations/routes. Response to be included with Program Document.

3.1.1 .4.A Confirm that the deployment routes and methods to be St. Lucie deployment routes and used will enable delivery of resources from the RRC methods have been reviewed by staging area to the site following a BDBEE. SAFER and enable delivery of off-site resources. Response to be included with Program Document.

3.2.1 .A The NRC staff endorsed the PWROG position paper on St. Lucie ELAP analysis CENTS the use of the Combustion Engineering Nuclear Transient code results are used for non-(CENTS) code in the ELAP analysis for Combustion reflux boiling conditions.

Engineering plants, with the limitation that it can only be Response to be included with applied to the flow conditions prior to reflux boiling Program Document.

initiation. Confirm that the applicable ELAP analyses for St. Lucie meet the above limitation on the use of CENTS.

3.2.l.1.A Confirm the plant-specific RCP seal leakage rates St. Lucie RCP seal leakage rates assumed for St. Lucie from time zero to the time when remain at 1 gpm/seal with early subcooling in the RCS cold-legs decreases to 50 CBO isolation included in SOE.

degrees F0 and confirm the impact of these leakage Response to be included with rates on the plant-specific time constraints and Program Document.

sequence of events (SOE). (Note: The TER, on page 30 of 69, listed an incorrect ADAMS accession number for the August 16, 2013, PWROG position paper on RCP seal leakage; it should be

__________ML13235A151). _______________

Page 15 of 46

L-2015-215, Enclosure Item Number Description Notes 3.2.1.2.B Confirm the assumption that the RCP seal leakage rate St. Lucie RCP Seal leakage is <1 is less than 1 gpm per RCP during an ELAP before the gpm per seal up to CBO isolation.

controlled bleed off is isolated. Response to be included with Program Document.

3.2.1.5 .A Confirm that the Rosemount pressure transmitters Rosemount transmitters are credited in an ELAP event will continue to function in confirmed to be adequate for the anticipated environmental conditions. ELAP conditions. The FPL EQ Program shows that the environmental conditions that would exist during an ELAP event are enveloped by the type testing done under the program.

Other essential instruments, not located in a harsh environment are found acceptable based on vendor specification sheets.

Response to be included with Program Document.

3.2.1 .9.A Justify' the use of the NOTRUMP computer code to AFW integrated flow rate determine the integrated flow rate required to remove requirement revised to compare to decay heat and sensible heat. CENTS code output. Response to be included with Program Document.

3.2.1 .9.B Confirm that the revised calculation for RCS makeup Flow supplied by AFW and SG flow demonstrates that the FLEX strategies and FLEX pumps confirmed to supply equipment can provide sufficient flow to accommodate adequate cooldown flow.

the sensible heat resulting from cooldown in the 2-6 Response to be included with hour time frame. Program Document.

3.2.1 .9.C Confirm that the pump criteria and the associated Reduced flow provided by RRC analysis support the adequacy of the RRC-supplied supplied pump is confirmed to be pumps to re-establish Shutdown Cooling for Phase 3. adequate for reestablishing Shutdown Cooling. Response to be included with Program Document.

3.2.4.2.A Confim- that the electrical equipment room equipment Shed heat loads are being is analyzed for operation up to a temperature of 129 recalculated to lower temperature degrees F° for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or that portable fans will be profile and required equipment used to provide adequate room ventilation, confirmed to function for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Response to be included with Program Document.

Page 16 of 46

L-2015-215, Enclosure Item Number Description Notes 3.2.4.4.A The NRC staff has reviewed the licensee Upgrades to the communications communications assessment (ADAMS Accession Nos. systems have been completed ML12307A116 and ML13057A033) and has (Engineering Change Package determined that the assessment for communications is 279287.

reasonable (ADAMS Accession No. ML13134A050).

Confirm that upgrades to the site's communications systems have been completed.

3.2.4.6.A Confirm that the measures to provide main control Shed heat loads are being room ventilation under high ambient temperatures recalculated to lower temperature during an ELAP event are sufficient to mitigate room profile and confirm measures are heat-up and allow operators to perform their functions. sufficient for habitability.

Response to be included with Program Document.

3 .2.4.7.A Confirm the availability of secondary sources of water New high wind missile separated to provide makeup to the CSTs/RWTs during Phase 2 2 nd potable water supply following a high wind missile event, connection ensure secondary source maintained for Phase 2.

Response to be included with Program Document.

3.2.4.10.A The revised battery load shed strategy is to initially Analysis indicates this shedding secure one battery, load shed and operate on the other is capable of increasing the battery, and return the secured battery to service before duration of the battery powered the first battery is depleted, thereby extending the instrumentation monitoring available coping time. Confirm that this revised strategy function on Unit 1 to is sufficient to power all critical loads during Phase 1, approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for each and can be implemented consistent with the assumed lA and lB station batteries (21.5 time constraints and SOE. hrs. total) and on Unit 2, 9.6 and 7.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for 2A and 2B station batteries, respectively (14.98 hrs.

total). This duration is considered sufficient.

3.3.2.A Confirm that considerations 1 and 3 of Section 11.8 of NEI 12-06 considerations will be NEI 12-06 will be addressed, so that: A) a historical addressed in Program Document record of previous mitigating strategies and the basis for controlled under Appendix B QA changes will be maintained, and B) a mitigating program maintains FLEX strategies change process will be adopted which provides strategies current and future a documented engineering basis that ensures that any configuration. Response to be change in FLEX strategy continues to ensure the key included with Program safety functions are met; or provide an appropriate Document.

alternative.

Page 17 of 46

L-20 15-215, Enclosure 6B NRC Staff Audit Questions, Safety Evaluation Review Items and Audit Debrief Items The NRC Staff conducted an onsite FLEX Program audit visit the week of November 17-2 1, 2014. Preceding and during the visit several Audit Questions, Safety Evaluation Review Items and Audit Debrief Items were submitted to PSL for response. Audit Questions related to and are numbered per non-docketed Audit Question from the NRC Staff and responded to by PSL in the autumn of 2013. These items supplemented Open and Confirmatory Items described in section 6A above. Responses were provided to the Staff with the summary of those provided below. Status of these items is pending with the NRC Staff.

Page 18 of 46

L-2015-215, Enclosure Audit Questions (AO)

Item Number Description Notes AQ2 FPL's integrated plan did not address the 1) Internal flood protection is principally a procedural interfaces considerations for seismic concern with respect to equipment located hazards associated with 1) large internal flooding within the ECCS Pump rooms. These sources that are not seismically robust and do rooms are located at the lowest RAB not require ac power, and 2) the use of ac power elevation and receive drains form higher to mitigate ground water in critical locations as elevations. The ECCS Pump Rooms are required by NEI 12-06 Section 6.3.3, protected by watertight doors and Considerations 2 and 3. Provide a discussion operator manual actions to isolate drains regarding any large internal flooding sources that to the rooms.

are not seismically robust and do not require ac 2) CLB flooding elevation (EL. 17.2') does power, and 2) the use of ac power to mitigate not reach minimum entrance to all seismic ground water in critical locations. If these category 1 buildings (EL. 19.5').

considerations are not applicable to PSL, then Preliminary results from the Flooding provide a discussion regarding why they are not Hazard Reevaluation indicate that a short applicable to PSL. duration of standing water occurs outside seismic category 1 building entrances resulting from local intense precipitation (LIP). Once the analysis is finalized the potential effects of the LIP will be reviewed and entered into the plants corrective action program. Any required interim measures will be implemented and the hazards will be addressed in the integrated assessment.

AQ3 FPL's integrated plan did not specifically address Current Licensing Basis NEI 12-06 Section 6.2.3.2, consideration 7 Dwtrn retato up r o regarding the potential need for dewatering or rqie sbidn nrne r bv extraction pumps, and consideration 8 regarding the plant probable maximum flood (PMF) the potential need for temporary flood barriers. hihwtrevaonPrUit1ndnt2 Provide a discussion of these flood mitigation UFSARs (Refs. 1&2), the PMF high water considerations (7 and 8) if they are applicable to level is 17.2 ft. Plant grade elevation is PSL or provide a discussion of why these flood 185fanmimuetrceoal mitigation provisions are not needed at PSL. simcCtgr ulig s1. t As an additional precaution, stop logs are deployed on specific doors to address wave run-up.

Flooding Reevaluation Preliminary results from the Flooding Hazard Reevaluation indicate that a short Page 19 of 46

L-2015-215, Enclosure Item Number JDescription JNotes duration of standing water occurs outside seismic category 1 building entrances resulting from local intense precipitation (LIP). Once the analysis is finalized the potential effects of the LIP will be reviewed and entered into the plants corrective action program. The hazard will be addressed in the integrated assessment and any required interim measures will be implemented.

Page 20 of 46

L-2015-215, Enclosure Item Number Description Notes AQ4 FPL's integrated plan provided some plans for Plant procedure 0005753 - "Severe procedures to be used to deploy portable Weather Preparations" provides direction equipment during flood conditions. For for the installation of stop logs.

Considerations 1 and 2, of NEI 12- 06 section Deployment of stop logs is initiated prior 6.2.3.3 FPL identified several procedures to be to the projected arrival of a hurricane at developed regarding deployment of FLEX the site. No barriers are required to be equipment and connection point considerations. installed for deployment of FLEX Provide a reference to procedures regarding equipment or connection to FLEX deployment of temporary flood barriers, per connection points.

Consideration 3 of NEI 12-06 Section 6.2.3.3, or discuss why these procedures are not required at PSL.

AQ6 If it is intended to credit significant improvement CBO isolation is performed under 1(2)-

for ELAP related to the isolation of controlled EOP-01 "Standard Post Trip Actions" prior bleed-off (CBO) lines, provide confirmation that to entry into 1(2)-EOP-10 "Station CBO isolation procedures, human factors Blackout". CBO isolation is accomplished requirements, and equipment qualifications are by closing valves SE-01-1 on Unit 1 and applicable to the ELAP event and are able to be V2524 on Unit 2. These valves actuate achieved within the time frames described in via vital DC powered solenoids (direct on section 5.3.1 of WCAP-16175. Unit I and via instrument air on Unit 2) operated by hand switches in the Main Control Room. The Unit 2 valve closes on

• loss of instrument air. The valves are

• Environmentally Qualified and are power

,via Class 1E DC buses that remain powered following an ELAP. Time Validation Studies have been performed to verify the CBO isolation is able to be achieved within the 10 minute time frame.

AQ 14 FPL's strategy for providing air flow to remove The FLEX Strategies for Spent Fuel Pool steam generated from pool boiling include Cooling include opening doors and securing open all Fuel Handling Building (FHB) deploying hoses in Phase 1 prior to doors, opening the large L-shaped habitability in the FHB being degraded.

door (no power required) and staging hoses for The L-Shaped door opening time without portable makeup or spray from the SFP FLEX power was estimated to be excessive pump. The open FHB doors will provide a compared to the available time, so the ventilation pathway for steam from the SFP in opening of the personnel doors at the addition to a pathway for laying hoses. It is not operating (62 ft) and ground (19.5 ft) clear from this discussion what the actual flow elevations was selected to allow for air path of steam and condensate will be since the flow and steam venting. The two doors at elevations of the various doors was not the 62 ft. have 3 ft. x 7 ft. openings. One discussed. No elevation diagrams were included is northwest of the Spent Fuel Pool (SFP) in the integrated plan. Provide a discussion surface elevation that is also 62 ft. The regarding SFP door location and elevations that other door is south of the SFP on the new

___________details how moisture will be vented from the SFP fuel storage area south wall that is open Page 21 of 46

L-20 15-215, Enclosure Item Number Description Notes building if boiling occurs. to the SFP via a normally open sliding doorway that has a 5.3 ft. x 30 ft. opening.

The double door at the 19.5 ft. has an 18 ft. x 15 ft. opening. The steam moisture will be vented out of the FHB via these openings if boiling occurs in the Spent Fuel pool.

AQ 18 NEI 12-06, Section 3.2.2, Paragraph (3) provides Plant equipment used during Phase 1 and AQ 45 that plant procedures/guidance should specify 2 do not require ventilation or auxiliary actions necessary to assure that equipment cooling. TDAFW is installed in an outdoor functionality can be maintained (including environment within the qualified Steam support systems or alternate method) in an Trestle. No ventilation fans are required ELAP/[LUHS] or can perform without ac power or for safety related design functions or post-normal access to the ultimate heat sink (UHS), ELAP conditions. TDAFW pump bearings such systems as auxiliary building cooling water, do not rely on external cooling systems.

service water, or component cooling water Charging and BAM pumps do not rely on cooling when ac power is lost during the ELAP external cooling water systems.

for Phase I and 2. For example, the potential Permanent plant active valves required need for cooling water for the TDAFW pump support Phase I and 2 strategies do not bearings was not discussed. Provide additional require ventilation to maintain an information regarding plans to provide ventilation environment that allows them to achieve and cooling to credited equipment when normal the position relied upon for FLEX cooling will not be available during the ELAP. strategies. Electrical equipment and instrumentation that are relied upon during an ELAP are environmentally qualified for their safety related design function and do not require cooling to be available during the ELAP.

AQ 19 Provide a discussion of battery room ventilation The design basis Battery Room roof AQ 44 to prevent hydrogen accumulation while exhausters will be powered when the recharging the batteries in phase 2 or 3. In your battery room chargers are placed in response, include a description of the exhaust operation to prevent hydrogen path if it is different from the design basis. accumulation. The exhausters will be powered by the same FLEX 480V DG used to power the battery chargers and draw flow from the battery rooms and exhaust to the outside atmosphere.

Page 22 of 46

L-2015-215, Enclosure Item Number jDescription JNotes AQ22 NEI 12-06, Section 3.2.2, Paragraph (12) Equipment relied upon to cope with an provides that: Plant procedures/guidance should ELAP at St. Lucie does not depend upon consider loss of heat tracing effects for heat tracing. Exterior piping for BDBEE equipment required to cope with an ELAP. makeup water sources is not heat traced.

Alternate steps, if needed, should be identified to For potential makeup from the RWT, boric supplement planned action. Provide a acid concentrations maintained in the discussion of the need for heat tracing for RWT are well below the 2.52 wt %

equipment required to cope with an ELAP. solubility limit of 32F. With respect to heat tracing of Boric Acid Makeup systems, St.

Lucie has implemented a Boric Acid Concentration Reduction program, an aspect of which was to remove heat tracing of the BAM piping. Heat tracing for CVCS piping from the BAMT to the charging pumps was eliminated on both units since the boron concentration in the BAM tanks was reduced from 8-12 wt %

to the range of 3.1-3.5 wt. % boric acid following EPU. The solubility limit of the boric acid at 3.5 wt % is 50 0F, which is well below the ambient temperature maintained in the RAB. Given the tropical climate of PSL, it is not expected that the ambient temperature inside the RAB will be reduced below the solubility limit during an ELAP, therefore, no heat tracing in the CVCS piping is required.

AQ23 NEI 12-06, Section 3.2.2, Paragraph (8) provides Installed DC lighting is available in the that: Plant procedures/guidance should identify Control Room, various locations in the the portable lighting (e.g., flashlights or plant (Appendix R) and will be headlamps) and communications systems supplemented with portable battery necessary for ingress and egress to plant areas operated lanterns as required.

required for deployment of FLEX strategies. On Dedicated radios with batteries are page 80 of 102 of the integrated plan, FPL noted maintained on smart chargers in the in Figure 3, PSL FLEX Electrical Connections Technical Support Center to supplement (Phase 1-3 Strategy Table), that emergency radios that normally used by on-duty lighting and plant communications would be personnel.

powered from the 480 VAC FLEX portable Satellite Phones with docking stations for generators. The sequence of events timetable on use in the Technical Support Center and page 7 4, Action Item 5 notes that the 480 VAC Control Rooms are maintained available generator will be deployed and connected charged and with spare batteries on smart between 6 - 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> into the event. Provide plans chargers.

for the availability of installed lighting and Portable 6 KW diesel generators are communications equipment prior to the available for charging batteries and connection of the 480 VAC portable generators. supplemental lighting as required.

Page 23 of 46

L-2015-215, Enclosure Item Number Description Notes AQ24 NEI 12-06, Section 3.2.2, Paragraph (9) provides A set of access keys will be provided to that: Plant procedures and guidance should the watchstanders.

consider the effects of ac power loss on area access, as well as the need to gain entry to the Protected Area and internal locked areas where remote equipment operation is necessary.

Provide plans for access to the protected area and internal locked areas of the plant considering loss of power to security systems.

AQ25 Describe how electrical isolation will be a) During normal operation, the new maintained such that (a) Class 1 E equipment is breakers will be racked out and locked protected from faults in portable/FLEX equipment open with springs discharged. Under this and (b) multiple sources do not attempt to power arrangement, isolation between the Class electrical buses. 1 E Electrical equipment and portable/FLEX equipment is maintained.

b) The strategy regarding prevention of multiple sources powering the electrical buses has evolved to having all FLEX power connection and breaker positioning be procedurally controlled. Bus preparation prior to Phase 2 will provide isolation from all incoming and outgoing connections precluding reconnection of multiple sources.

AQ28 NEl 12-06, Section 3.2.2, guideline (15) and St. Lucie will commit to the generic EPRI Section 11.5, specify requirements regarding industry program for maintenance and maintenance, equipment unavailability, and testing of FLEX electrical equipment.

testing. In its integrated plan, FPL described establishing a maintenance program plan based on EPRI guidelines and using existing plant maintenance programs to identify and document maintenance and testing requirements. Please confirm your intention to commit to the generic EPRI industry program for maintenance and testing of FLEX electrical equipment such as batteries, cables, and diesel generators. [See NRC endorsement letter dated October 7, 2013; NRC ADAMS Accession No. ML13276A224] ________________

Page 24 of 46

L-2015-2 15, Enclosure Item Number Description Notes AQ 31 Identify the installed non-safety related systems PSL credits no installed non-safety related or equipment that are credited in establishing the systems or equipment for Phase 1 mitigation strategies. For the identified systems strategies. In Phase 2, PSL credits an or equipment, discuss the intended mitigation underground 12' potable water supply line functions, and justify that they are available and a number of backup non-safety related reliable to provide the desired functions on tanks (CWSTs, TWST, PWSTs, etc) as an demand during the ELAP conditions. alternate strategy to supply demineralized or potable water for CST and RWT makeup. Based on redundancy and separation, there is reasonable assurance that a number of these alternate water supplies will be available for use following BDBEEs.

In Phase 3, PSL credits non-safety related traveling water screens, located within qualified intake structures, to provide debris control for the RRC pumps restoring UHS flow. Due to their construction, there is reasonable assurance that one or more of the four traveling water screens will be available to support the FLEX Phase 3 LUHS strategy.

AQ39 Provide a summary of the sizing calculation for 480 - A 480 VAC FLEX DG with a standby the FLEX generators to show that they can rating of 405 kW (437.5 kVA at 0.8 power supply the loads assumed in phases 2 and 3. factor) is required, one per unit.

4160 - Two 4160 VAC FLEX DGs with continuous ratings of 1000 kW (in parallel

- combined 2 MW; 2.5 MVA at 0.8 power factor) will be utilized for each unit.

AQ42 On Page 24 of the Mitigation Plan, under PWR A milestone has been created in the Saint Portable Equipment Phase 2, the licensee Lucie's Fukushima response schedule to described the portable diesel driven pump (SG complete the validation of the deployment FLEX pump) being deployed for injection into the and installation of the SG FLEX pump.

steam generators (SGs) in the event that the The validation will be performed using the turbine-driven auxiliary feedwater (TDAFW) guidance for time sensitive action pump fails. The licensee indicted that the time validation contained in the NEI endorsed and resources to make connections of the SG guidance for FLEX strategies. The FLEX pump will be validated. Provide a validation will be performed by the milestone for completing its validation for required minimum staff compliment as connection of the SG FLEX pump for Phase 2 required by Order EA-12-049.

when needed.

Page 25 of 46

L-2015-215, Enclosure Item Number Description [Notes AQ48 Motive Force for the atmospheric dump valve The nitrogen backup supply system will (ADV) Operations: (a) Specify the size of the be capable of supporting operation of the ADV backup nitrogen supply source and the ADVs for 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />. Using historical data required time for its use as motive force to on valve operator leakage a calculation operate the ADVs for mitigating an ELAP event; has been prepared to determine the (b) Discuss the analysis determining the size of required size of the backup nitrogen the subject nitrogen supply to show that the supply. This calculation determined that nitrogen sources are available and adequate, less than one St Lucie standard size lasting for the required time; (c) Discuss the cylinder is all that is required. To provide electrical power supply that is required for margin, two cylinders have been provided operators to throttle steam flow through the to support the operation of each ADV. No ADVs within the required time and show that the electrical power is required to support the power is available and adequate for the intended operation of the Unit 1 ADVs. The Unit 2 use before the operator takes actions to ADVs are powered from the Vital DC manually operate the ADVs; and (d) Discuss the power system. Based on the recovery operator actions that are required to operate timeline the backup nitrogen supply must ADVs manually and show that the required be operational two hours after the event actions can be completed within the required has occurred. All of the required time. components are pre-staged in the vicinity of the ADVs. Operator actions to place the backup nitrogen in service will be to connect two hose assemblies, which already include the required valves and fittings between the nitrogen cylinder and a permanently installed connection on the ADV pneumatic control line. Control valves are included as part of the hose assemblies so that the pressure to the ADV operator can be modulated and in turn the ADV position can be changed as required.

Page 26 of 46

L-2015-215, Enclosure Item Number fDescription jNotes AQ49 Uncontrolled Cooldown - Clarify whether the The safety related ADV's are located in ADVs or upstream associated piping is protected the steam trestles which are safety related from external events such as tornado missiles. If structures qualified for tornado missile not, address the following questions: (a) Clarify and seismic loads. The ADV's and whether damage to the ADV or upstream upstream associated piping are protected associated piping could occur during an ELAP from tornado wind/missile events.

that would result in an uncontrolled cooldown of the reactor coolant system; (b) Clarify whether postulated damage would be limited to a single ADV and/or associated piping, or whether failures could be postulated resulting in an uncontrolled cooldown affecting both steam generators; (c) If ELAP scenarios involving the uncontrolled cooldown of one or more steam generators may be postulated, describe key operator actions that would be taken to mitigate these events; (d) If ELAP scenarios involving the uncontrolled cooldown of one or more steam generators may be postulated, provide an analysis demonstrating that the intended mitigating actions would lead to satisfaction of the requirements of Order EA-12-049 for these cases; and (e) As applicable, if the operator actions to mitigate an ELAP event involving an uncontrolled cooldown results in an asymmetric cooldown of the reactor coolant system, address the consequences of the asymmetric cooldown on the mixing of boric acid that is added to the reactor coolant system to ensure sub-criticality.

Page 27 of 46

L-2015-2 15, Enclosure Item Number Description Notes AQ 51 Clarify whether you plan to abide by the NEI PSL will abide by the NEI position paper position paper addressing mitigating strategies in addressing mitigating strategies in shutdown and refueling modes that is dated shutdown and refueling modes that is September 18, 2013 (ADAMS Accession No. ML dated September 18, 2013 13273A514), which has been endorsed by the (ADAMS Accession No. ML13273A514),

NRC staff (ADAMS Accession No. ML which has been endorsed by the NRC 1 3267A382). If not, clarify how mitigating staff (ADAMS Accession No.

strategies for shutdown and refueling modes will ML13267A382 be addressed and provide justification for the Additionally, FSG-14, Shutdown RCS planned approach. makeup, has been developed. This guideline provides instructions to establish RCS makeup flowpaths during an extended loss of AC power (ELAP) event, occurring while shutdown with Shutdown Cooling in service. FSG-14 will have guidance for makeup to the RCS from multiple sources including: FLEX pump, Safety Injection Tanks if available, charging pump drawing from the RWVT or BAMT.

Page 28 of 46

L-2015-215, Enclosure Safety Evaluation (SE) Review Items Item JDescription Notes SE la. The FLEX Strategies for Reactor

1. (RCS Venting) The generic analysis inWCAP-17601-P Review strictly addressed ELAP coping time without consideration Cooldown and Heat Removal will include Item 1 of the actions directed by a site's mitigating strategies. venting the ROS when it is necessary to WCAP-17792-P extends these analytical results through accommodate charging the RCS with borated explicit consideration of mitigating strategies involving RCS water in order to maintain shutdown margin.

makeup and boration. In support of the RCS makeup and lb.i.The vent path is the Reactor Coolant Gas boration strategies proposed therein, a generic Vent System that is operated by opening and recommendation is made that PWRs vent the RCS while closing the vessel head vent.

makeup is being provided. Provide the following 1lb.ii The criteria used for opening the vent is information in regard to this topic: at the start of charging the RCS with borated

a. Will the mitigating strategy include venting of the RCS? water.

b. If so, please provide the following information: 1lb.iii The vent will be closed upon completion

i. The vent path to be used and the means for its opening of charging the RCS with borated water.

and closure. I b.iv The vent will initially pass steam and ii. The criteria for opening the vent path. once the reactor vessel level rises to the top of iii. The criteria for closing the vent path. the vessel head, the vent passes liquid. The iv. Clarification as to whether the vent path could vent is designed to close against full RCS experience two-phase or single-phase liquid flow during an pressure that is well above the 750 psig ELAP. Iftwo-phase or liquid flow is a possibility, clarify expected when passing the 44 gpm of a whether the vent path is designed to ensure isolation charging pump.

capability after relieving two-phase or liquid flow. lb.v The instrumentation relied upon for

v. If relief of two-phase or liquid flow is to be avoided, verifying the flow path is isolated are the discuss the availability of instrumentation or other means pressurizer pressure and reactor vessel level that would ensure that the vent path is isolated prior to transmitters.

departing from single-phase steam flow. lb.vi PORVs are not used for RCS Makeup &

vi. If a pressurizer power-operated relief valve (PORV) is to Boration.

be used for RCS venting, clarify whether the associated lb.vii PORVs are not used for RCS Makeup &

block valve would be available (or the timeline by which it Boration.

could be repowered) in the case that the PORV were to

• f Page 29 of 46

L-2015-215, Enclosure Item Description Notes SE stick open. If applicable, further explain why opening the 1lc. RCS Venting will be used.

Review pressurizer PORV is justified under ELAP conditions ifthe Item 1 associated block valve would not be available.

(Cont'd) vii. If a pressurizer PORV is to be used for RCS venting, clarify whether FLEX RCS makeup pumps and FLEX steam generator makeup pumps will both be available prior to opening the PORV. If they will not both be available, provide justification.

c. If RCS venting will not be used, provide the following information:

i. The expected RCS temperature and pressure after the necessary quantity of borated makeup has been added to an unvented RCS.

ii. Justification that the potential impacts of unvented makeup will not adversely affect the proposed mitigating strategy (e.g., FLEX pump discharge pressures will not be challenged, plant will not reach water solid condition, adequate boric acid can be injected, increased RCS leakage will not adversely affect the integrated plan timeline, etc.).

SE (Timeline to reflux cooling) Clarify whether procedural Procedural guidance for the timing of Review guidance for the timing of providing makeup to the providing makeup to the reactor coolant Item 2 reactor coolant system is based on analysis in system is based on the earlier of (1) decrease WCAP-17792-P, pages 3-10 through 3-16. If so, in AT indicating departure from single phase provide justification for basing the timing of primary NC or (2) transition to extended cooldown and makeup on the assumption that reactor coolant pump not on the analysis in WCAP-17792-P. RCP seal leakage rates that are less than the maximum Seal leakage assumptions for PSL are 1 expected value under ELAP conditions will not gpm/pump vs 15 gpm/pump described in increase. WCAP-1 7792-P analysis.

Page 30 of 46

L-2015-215, Enclosure Item Description JNotes SE Provide confirmation that appropriate human factors EN-AA-103, Human Factors Program, provides the Review are applied for the implementation of the FLEX guidance for ensure design features facilitate the Item 3 strategies. safe and reliable performance of operations by the following:

• Personnel tasks can be accomplished within time and performance criteria

• Human-system interfaces, procedures, staffing/qualifications, training, and management and organizational arrangements support personnel situation awareness

• Design will support personnel in maintaining vigilance over plant operations and provide acceptable workload levels, i.e., minimize periods of under- and over-load

• Human-system interfaces will minimize personnel error and will support error detection and recovery capability In addition NE! has endorsed a FLEX verification and validation document that outlines the process to be use by licensees to ensure the required tasks, manual actions and decisions for FLEX strategies are feasible and may be implemented within the constraints identified in the Overall Integrated Plan (OIP) for Order EA-12-049.

Also, the use of color coded 480 Volt electrical connections, cables, hoses and hose connections will enhance the human -system interface. FLEX equipment tags will be installed on plant equipment to ensure easy identification during deployment and installation of FLEX equipment.

Training, using the SAT process, will be administered to Operations, Emergency Responders, Security and Decision Makers commensurate with the level on interface required by the FLEX strategies.

Page 31 of 46

L-2015-215, Enclosure Item jDescription JNotes SE a. Discuss the design of the suction strainers used a. In Phase 2, the intake canal is used as the Review with FLEX pumps taking suction from raw water last selected water source for the FLEX SG Item 4 sources, including perforation dimension(s) and Pump and the FLEX SFP Pump. In Phase 3, approximate surface area. PSL credits the intake traveling screens to

b. Provide reasonable assurance that the strainers provide for debris control for the RRC supplied will not be clogged with debris (accounting for LUHS pumps. Perforation size in these conditions following, flooding, severe storms, screens is 3/8" with a surface area of 2 ft. x 10 earthquakes or other natural hazards), or else that ft. per panel and 13 panels on front (normally the strainers can be cleaned of debris at a frequency rising) side and 13 panels in series on back that is sufficient to provide the required flow. In the side of screen frame.

response, consider the following factors: b. The screens normally pass 120,000 gpm of

i. The timing at which FLEX pumps would take circulating water flow. For the FLEX LUHS suction on raw water relative to the onset and pump, flow to feed both PSL Unit 1 and Unit 2 duration of the natural hazard. is 10,000 gpm. The total flow for the other ii. The timing at which FLEX pumps would take FLEX Pumps is 1200 gpm maximum for the 3 suction on raw water relative to the timing at which pumps. Water velocity across the screen, augmented staffing would be available onsite. normally at 2.7 fps, is correspondingly iii. Whether multiple suction hoses exist for each reduced by 90% for the largest FLEX pump FLEX pump taking suction on raw water, such that flow and, thus, there is reasonable assurance flow interruption would not be required to clean that debris loading and resultant screen suction strainers. clogging will be minimal.

i. The FLEX SFP pump or FLEX SG pump could take suction during Phase 2 as early as 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following the onset of the BOBEE.

The FLEX LUHS pump will take suction on the intake after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in Phase 3.

ii. Augmented staff will be available onsite as early as 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following the onset of the BDBEE.

iii. There is no requirement to clean the screens due to their configuration. Should their cleaning become necessary, they are separate from the suction hose so no flow interruption would be necessary.

SE Provide information on the refueling strategy for The refueling of diesel powered FLEX Review diesel powered FLEX equipment. equipment is provided by a 1000 gallon Item 5 refueling trailer. This refueler will be filled from the Unit 2 Diesel Oil Storage Tanks (DOSTs) and delivered to FLEX equipment to fill their on-board tanks. The refueler will return to the Unit 2 DOSTs for refilling as its inventory is depleted.

Page 32 of 46

L-2015-2 15, Enclosure Daily Debrief Items (DI)

Item Description Notes 11/17/2015 Safety Injection Tank (SIT) isolation Evaluation White Paper prepared and DI 5 timing during RCS Cooldown to avoid reviewed that provided the elevated RCS Nitrogen Injection pressure required that prevents nitrogen injection from the SIT. Corresponding temperatures also provided that would be maintained until SIT isolation is performed.

11/19/2015 Reactor Coolant System (RCS) Evaluation White Paper prepared and DI-7 shrinkage and available injection volume reviewed that discussed that with the 10%

from SIT's for borated water addition remaining water volume in the SIT assumed considering elevated pressure described for prevention of nitrogen injection, in earlier Debrief Item (11/17/15-DI5) associated borated water injection exceeds that calculated for maintaining shutdown margin (SDM). SDM Reactivity Calculation that assumes no ROS leakage and, thus, less volume available for injection.

7 Potential Draft Safety Evaluation Impacts Draft NRC Safety Evaluation has not been received.

8 References The following references support the updates to the Overall Integrated Plan described in this Attachment.

1. FPL Letter L-2013-084 to NRC, Florida Power & Light (FPL)/St. Lucie's Overall Integrated Plan in Response to March 12. 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) dated February 28, 2013

2. FPL Letter L-2013-192 to NRC, Florida Power & Light (FPL)/St. Lucie's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049) dated June 18, 2013

3. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012

4. NEI 12-06 Rev 0, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide (including supplemental guidance contained within posted Flex Guidance Inquiry Forms)

5. WCAP-17601-P Rev 1, Reactor Coolant System Response to Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs, January 2013

6. FPL Letter L-2013-254 to NRC, Florida Power & Light (FPL)/St. Lucie's First Overall Integrated Plan Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Page 33 of 46

L-2015-2 15, Enclosure Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated August 28, 2013

7. NRC Endorsement of Reference 8, Agencywide Documents Access and Management Systems (ADAMS)

Accession No. M1L13276A183, dated January 8, 2014

8. Westinghouse Position Paper entitled "Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in Support of the Pressurized Water Reactor Owners Group (PWROG)", ADAMS Accession No. MvL13235A135, dated August 15, 2013

9. NEI Position Paper entitled "Shutdown / Refueling Modes", ADAMS Accession No. ML13273A514, dated September 18, 2013

10. NRC Endorsement of Reference 9, ADAMS Accession No. ML13267A382, dated September 30, 2013

11. Electric Power Research Institute (EPRI) Report 3002000623 entitled "Nuclear Maintenance Applications Center: Preventive Maintenance Basis for FLEX Equipment", ADAMS Accession No. M1L13276A573, dated September 2013

12. NRC Endorsement of Reference 11, ADAMS Accession No. ML13276A224, dated October 7, 2013

13. Interim Staff Evaluation and Audit Report by the Office of Nuclear Reactor Regulation Related to Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Florida Power and Light Company, St. Lucie Plant, Units 1 and 2, Docket Nos. 50-335 and 50-389, dated February 6, 2014

14. FPL Letter L-2014-063 to NRC, Florida Power & Light (FPL)/St. Lucie's Second Overall Integrated Plan Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 26, 2014

15. FPL Letter L-2014-215 to NRC, Florida Power & Light (FPL) Response to NRC 10 CFR(f) Request for Information Update Regarding Near-Term Task Force Recommendation 2.3, Seismic, dated June 30, 2014

16. Westinghouse Letter LTR-FSE- 13-46, Rev. 0-A (DRAFT), Westinghouse Response to NRC Generic Request for Additional Information (RAT) on Boron Mixing in Support of the Pressurized Water Reactor Owner's Group, June 11, 2013

17. FPL Letter L-20 14-274 to NRC, Florida Power & Light (FPL)/St. Lucie's Third Overall Integrated Plan Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated August 27, 2014

18. FPL Engineering Evaluation PSL-ENG-SECS-14-003, Rev. 0 NRC Order EA-12-049 Response (Fukushima) PSL Tornado Missile

19. FPL Letter L-201 5-049 to NRC, Florida Power & Light (FPL)/St. Lucie's Fourth Overall Integrated Plan Status Report in Response to March 12, 2012 commission Order Modifying Licenses with Regard to Requirement for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 23, 2015 Page 34 of 46

L-20 15-215, Enclosure SIMPUFRED ONE-UNE DIAGRAM OF UNIT 1 CLASS 1E AUXILIARY ELECTRICAL DISTRIBUTION SYSTEM Figure 1 PSL FLEX Electrical Connections (Unit 1) (Rev 0A)

Page 35 of 46

L-2015-215, Enclosure SIMPUFIED ONE-UNE DIAGRAM OF UNIT 2 CLASS 1E AUXILIARY ELECTRICAL DISTRIBUTION SYSTEM 4.16 SWGR 2A2 4.16 SWGR 282 UNIT 2 EDO EDO

• DG I ~ G

• ;R 2R]

....... 'T" I

PUMP ZA IPSI PUMP PUMP IT TO UNIT 1 282 SS" Figure 2 PSL FLEX Electrical Connections (Unit 2) (Rev 0A)

Page 36 of 46

a L-20 15-21l5, Enclosure Connection made on bonnets of abandoned check valves for FLEX CST Pump Discharge and FLEX SG Pump Suction via Temporary Wye Fitting Portion of Drawing 8770-G-080 Sh. 4 Branch connections for FLEX connections for FLEX CST Pump Discharge and FLEX SG Pump Suction via Temporary Wye Fitting Portion of Drawing 2998-G-080 Sh. 213 Figure 11 Connections for CST FLEX Pump Suction on CSTs (Rev 1)

Page 37 of 46

L-20 15-215, Enclosure Connection made on bonnets of abandoned check valves for FLEX CST Pump Discharge and FLEX SG Pump Discharge via Temporary Wye Fitting Portion of Drawing 8770-G-080 Sh. 4 Branch connections for FLEX connections for FLEX CST Pump Discharge and FLEX SG Pump Discharge via Temporary Wye Fitting Portion of Drawing 2998-G-080 Sh. 2B Figure 12 Connections for CST/SG FLEX Pump Discharge for CST Fill (Rev 1)

Page 38 of 46

L-20 15-215, Enclosure Install a 4" isolation valve and hose connection to the AFW pump 1C(2C) discharge piping for Steam Generator Injection by using a FLEX pump.

tI--uF ?Ia

_ C Oeo

=7O I IO w-P-1i *1S2 Portion of Drawinag 8770-G-080 Sh. 4 Portion of Drawingi 2998-G-080 Sh. 2B Figure 13 Connections for SG FLEX Pump Discharge to AFW Pump Discharge Lines (Rev OA)

Page 39 of 46

L-20 15-215, Enclosure Install primary and secondary 3" isolation valves & hose connections on the LPSI 1AI1B Pumps common discharge piping. For RCS cold leg injection with FLEX SG Pump drawing suction from the RWT.

• L 2 / Il ILCOIPW ART I nUJiX) UPtA t

t 1W WI PUSSIIE SAfElY RIEClUI P1WII Portion of Drawing 8770-G-078 Sh. 130B Install 3" isolation valves and hose connections on each of the LPSI 2A & 2B Pumps discharge piping.

For RCS cold leg injection with FLEX SG Pump drawing suction from the RWT.

• m Portion of Drawing 2998-G-078 Sh. 130B Figure 14 Connections for SG FLEX Pump Discharge to LPSI Pump Discharge Lines (Rev 1)

Page 40 of 46

L-20 15-215, Enclosure R4TAME S1R~)

REXCamedion~ R.mov. Z4 F~nh..~d Imlull mg.dW pwW~www~t~omIor~Pwop INTAKE COOLING PUMP 15 WATER Figure 17 Connections for NSRC LUHS Pumping System (Unit 1) (Rev 0A)

Page 41 of 46

L-2015-21 5, Enclosure HTMcEcOQmcWAlER p~M,a Figure 18 Connections for NSRC LUHS Pumping System (Unit 2) (Rev OA)

Page 42 of 46

L-20 15-215, Enclosure VI5U*

PI*AI*Y WATER STtWA TANK PRIMARV WAlER MWP lA Ft PRIMRYWAlIER MW29 Figure 21 Connections for CST/SG FLEX Pump Suction From PWSTs (Unit 2, Unit 1 Similar) (Rev 0A)

Page 43 of 46

L-2015-2 15, Enclosure Install a 3" isolation valve and hose connection on SFP Pumps 1A & 2A Suction piping. For SFP Hardened Makeup from FLEX SFP Pump FLEX RJuL PtIPPo*0 lA I,

Portion of Drawing 8770-G-078 Sh. 140 Figure 22 Connection for SFP FLEX Pump Discharge to Fuel Pool Pump (Unit 1, Unit 2 Similar) (Rev 0)

Page 44 of 46

L-20 15-215, Enclosure COHN FORZ PORTABLE COLIN FOR PORr*aI.E RLEX pUUP. tfLEX PUILP.

II IIFLEX Connections for FLEX SFP Pump r---tSuction and FLEX CST Pump Suctions I-ll

"" "" "- -FLIEX PUMP.

V1 55 169

- - CST Pump Suctions " LXRlP

"" ""'-RFX PUMP.

V155174 Portions of Drawing 8770-G-084 Sh 1A Figure 23 Connections for Secondary Water Sources (Ft. Pierce Utilities) for SFP FLEX Pump Suction and FLEX CST Pump Suctions (Rev. 0)

Page 45 of 46

L-201 5-215, Enclosure

.. OLDAY TKS 2A I*

I I

I G-096 SH2IA (A--

Portion of 2998-G-086 Sh. 1 Figure 24 Connections for Diesel Oil Gravity Drain Connections from Unit 2 Diesel Oil Storage Tanks (Rev 0)

Page 46 of 46